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“international transaction”

Transfer PricingSection 92BSection 92B3,408 judgments

The decision most relied on for international transaction is Sony Ericsson Mobile Communications India Pvt. Ltd. v. CIT (374 ITR 118), cited in 499 judgments on BharatTax.

Leading authorities on international transaction

Sony Ericsson Mobile Communications India Pvt. Ltd. v. CIT
374 ITR 118 · 2015 · High Court
499
citing judgments

The existence of an international transaction for Advertising and Marketing Promotion (AMP) expenditure requires the revenue to discharge the burden of proof. An explanation inserted under Section 92B does not automatically make AMP expenditure an international transaction.

CIT v. EKL Appliances Ltd.
345 ITR 241 · 2012 · High Court
422
citing judgments

Transfer pricing adjustments for outstanding receivables are permissible only if the Tax Officer establishes, through analysis over a period, a pattern indicating an international transaction intended to benefit an associated enterprise. The Tax Officer cannot question purely business decisions like royalty payments or exceed jurisdiction by applying cost-benefit analysis to determine the arm's length price of services.

India Vs. Azadi Bachao Andolan 263 ITR 706 (SC); and Vodafone International Holdings B.V v. Union of India
341 ITR 1 · 2012 · Supreme Court
295
citing judgments

Legitimate tax planning is permissible, allowing taxpayers to arrange their affairs to minimize tax liabilities while respecting the "look at test" for transaction genuineness and the separate entity principle in corporate taxation. The source of funds for treaty-beneficial structures does not automatically invalidate the transaction.

Maruti Suzuki India Ltd. v. CIT
381 ITR 117 · 2016 · High Court
220
citing judgments

The Bright Line Test (BLT) is not a recognized method under the Income-tax Act and Rules for benchmarking advertising, marketing, and promotion (AMP) expenses or for determining the existence of an international transaction or its Arm's Length Price. The Revenue must first establish the existence and price of an international transaction before seeking an ALP adjustment.

Vodafone India Services (P.) Ltd. v. Union of India
368 ITR 1 · 2014 · High Court
172
citing judgments

The issue of shares and share premium is a capital account transaction, not an income-generating event, therefore Chapter X (Transfer Pricing) provisions are not attracted to deem notional or hypothetical income from such transactions.

Sir Kikabhai Premchand v. CIT
24 ITR 506 · 1953 · Supreme Court
156
citing judgments

One cannot make a taxable profit or loss from transactions with oneself, as profit only arises from dealings with external third parties, even when transferring assets between different accounts or divisions of the same entity.

PCIT v. Redington (India) Ltd.
430 ITR 298 · 2021 · High Court
132
citing judgments

A corporate guarantee issued to Associated Enterprises (AEs) is an international transaction under Section 92B, requiring adjustments for guarantee commission due to inherent risk. The reasonable arm's length rate for benchmarking such corporate guarantees can be determined using internal or external comparable uncontrolled prices.

Bausch & Lomb Eye Care (India) Pvt. Ltd. v. Additional CIT
381 ITR 227 · 2016 · High Court
127
citing judgments

The existence of an international transaction must be established before its arm's length price can be determined. An alleged 'excessive' AMP expenditure cannot unilaterally expand the scope of an international transaction if its existence is contested.

Judgments citing international transaction

Lava International Limited, New Delhi vs. ACIT Circle-13(1), New Delhi

In the result, the appeal of the assessee is partly allowed

ITA 532/DEL/2021[2016-17]Status: DisposedITAT Delhi17 Apr 2025AY 2016-17

Bench: Shri Anubhav Sharma & Shri Brajesh Kumar Singh[Assessment Year: 2016-17]

Section 143(3)Section 92BSection 92C

SBLC*) on behalf of the associated enterprise, and since the transaction of facilitating the issuance of SBLC has no bearing on the cost or international transaction in term of section 92B of the Act.” 3. The ld. AR has submitted that this guarantee was issued pursuant to obligation ... difference between bank guarantee and SBLCs as compared to corporate guarantees. Further, we have also concluded that issuance of SBLC in the international transaction can be put to ALP tests. As for completeness, the observations and finding of the Bench in the case of Anand NVH Products

Assistant Commissioner of Income Tax Central Circle1-(2), Hyderabad vs. M/S. Vpr Mining Infrastructure Pvt Ltd, Hyderabad

Accordingly, the learned CIT(A) partly allowed the appeal of the assessee

ITA 90/HYD/2021[2015-16]Status: DisposedITAT Hyderabad16 Apr 2025AY 2015-16

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: Shri S K Gupta, AdvocateFor Respondent: MS. M. Narmada, CIT-DR
Section 115JSection 153A

examination of the seized/impounded material and information furnished by the assessee during the assessment proceedings observed that the assessee had entered into the international transactions with it's AE, PT VPR Laxmindo under two heads i.e., receipt of lease rentals at Rs.56,30,38,068/- and disinvestment in equity

Oakton Global Technology Services Centre (I) Private Limited, Hyderabad vs. Dy. Commissioner of Income Tax, Circle-16(2), Hyderabad

In the result, the appeal of the assessee in ITA No

ITA 32/HYD/2019[2014-15]Status: DisposedITAT Hyderabad16 Apr 2025AY 2014-15

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri Ravi Bharadawaj, C.AFor Respondent: Shri B. Bala Krishna, CIT-DR
Section 143(3)Section 92B

Rules, 1962 ("Rules") and undertaking a fresh economic analysis during the course of assessment proceedings and accordingly making a TP adjustment to the international transactions of providing software services to its AE; Rejection of use of multiple year data 2) Rejecting the use of multiple year data and using data ... risk differences 8) Not adjusting the net margins of the comparable companies selected taking into account the functional and risk differences between the international transaction of the Appellant and the comparable companies in accordance with the provisions of Rule 10B(1) (e) of the Rules; Negative Working Capital Adjustment

Oakton Global Technology Services Centre (India) Private Limited, Hyderabad vs. Deputy Commissioner of Income Tax, Circle-16(2), Hyderabad

In the result, the appeal of the assessee in ITA No

ITA 2130/HYD/2017[2013-14]Status: DisposedITAT Hyderabad16 Apr 2025AY 2013-14

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri Ravi Bharadawaj, C.AFor Respondent: Shri B. Bala Krishna, CIT-DR
Section 143(3)Section 92B

Rules, 1962 ("Rules") and undertaking a fresh economic analysis during the course of assessment proceedings and accordingly making a TP adjustment to the international transactions of providing software services to its AE; Rejection of use of multiple year data 2) Rejecting the use of multiple year data and using data ... risk differences 8) Not adjusting the net margins of the comparable companies selected taking into account the functional and risk differences between the international transaction of the Appellant and the comparable companies in accordance with the provisions of Rule 10B(1) (e) of the Rules; Negative Working Capital Adjustment

DCIT Cir-4(1), Kolkata, Aayakar Bhawan vs. Mcleod Russel India Ltd, Kolkata

In the result, the appeal filed by the revenue is dismissed

ITA 1169/KOL/2023[2013-14]Status: DisposedITAT Kolkata16 Apr 2025AY 2013-14

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

Section 115OSection 143(2)Section 14ASection 80ISection 92C

notices u/s 143(2) and subsequently 142(1) were issued, since the assessee company during the proceedings under assessment year had entered into the international transaction within the meaning of Section 92CA of the Act, hence, the case of the assessee was referred to the concerned transfer pricing officer after ... comparable uncontrolled transaction, or a number of such transactions, is identified. ii) Such price is adjusted to account for differences, if any, between the international transaction and the comparable uncontrolled transactions or between the enterprises entering into such transactions, which could materially affect the price int eh open market

Ajay Bakliwal, Kota vs. ACIT, Central Circle, Kota

In the result, the appeal of the assessee is allowed

ITA 1279/JPR/2024[2017-18]Status: DisposedITAT Jaipur11 Apr 2025AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. Rajendra Sisodia, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 132(1)Section 139Section 143(3)Section 153ASection 154Section 270A

taxmann.com 862 has observed that the issues with regard to deduction under section 80-IA of the Act and arm's length price of international transaction between the assessee and its associated enterprise (AY 2003-04 to 05-06) could not and ought not to have been examined

Hempel Singapore Pte Ltd, Mumbai vs. Deputy Commissioner of Income Tax International Taxation Circle 2(2)(2), Mumbai

Appeal are allowed

ITA 946/MUM/2025[2022-23]Status: DisposedITAT Mumbai11 Apr 2025AY 2022-23

Bench: Shri Pawan Singh, Jm & Ms Padmavathy S, Am

For Respondent: Shri Krishna Kumar- Sr. DR
Section 143(3)Section 144BSection 144C(13)Section 147Section 153Section 9

case and in law, the Hon'ble DRP/Ld. AO erred in: 2.6.1 not appreciating that no further attribution of income is warranted, once the international transaction has been accepted to be at arm's length in the assessment proceeding of the Indian agent ie. Hempel Paints (India) Pvt. Ltd. ('Hempel

Transunion International Inc., Mumbai vs. Deputy Comm. of Income Tax (International Taxation)-4(1)(2), Mumbai

Appeal of the assessee is allowed

ITA 2698/MUM/2022[2017-18]Status: DisposedITAT Mumbai11 Apr 2025AY 2017-18

Bench: Shri Pawan Singh, Jm & Ms Padmavathy S, Am

For Appellant: Shri J.D. Mistry, Sr. Adv. a/w
Section 142(1)Section 143(3)Section 144CSection 47

case of Vodafone Idea Limited (Supra) – “5. In the meantime, the TPO passed an order proposing an adjustment to the value of the international transaction of Petitioner. The Assessing Officer ("AO") passed a draft order dated 29th December 2019 under section 144C(1) of the Act for the relevant

Marico Ltd, Mumbai vs. DCIT Cen Cir-35, Mumbai

ITA 7044/MUM/2008[2005-2006]Status: DisposedITAT Mumbai11 Apr 2025AY 2005-2006

Bench: Shri Pawan Singh, Jm & Ms Padmavathy S, Am

Section 115JSection 80HSection 80I

Adjustment in respect of guarantee commission 31. The AO noticed that the assessee in the Transfer Pricing Report furnished under section 92E relating to International Transaction entered by the assessee with its Associated Enterprises (AE) that the assessee has not charged commission on guarantee given to its AE in Bangladesh ... addition by applying 0.8% as Guarantee Commission. 32. The ld. AR during the course of hearing fairly conceded that the impugned transactions are international transactions and made an alternate plea that the guarantee commission be restricted to 0.5% by relying on the following decisions: a. Cadilla Pharmaceuticals Ltd. vs. ACIT

M/S. Marico Ltd, Mumbai vs. The ACIT Cen Cir-35, Mumbai

ITA 3533/MUM/2008[2004-2005]Status: DisposedITAT Mumbai11 Apr 2025AY 2004-2005

Bench: Shri Pawan Singh, Jm & Ms Padmavathy S, Am

Section 115JSection 80HSection 80I

Adjustment in respect of guarantee commission 31. The AO noticed that the assessee in the Transfer Pricing Report furnished under section 92E relating to International Transaction entered by the assessee with its Associated Enterprises (AE) that the assessee has not charged commission on guarantee given to its AE in Bangladesh ... addition by applying 0.8% as Guarantee Commission. 32. The ld. AR during the course of hearing fairly conceded that the impugned transactions are international transactions and made an alternate plea that the guarantee commission be restricted to 0.5% by relying on the following decisions: a. Cadilla Pharmaceuticals Ltd. vs. ACIT

The ACIT CC-35, Mumbai vs. M/S. Marico Ltd, Mumbai

ITA 3152/MUM/2008[2004-2005]Status: DisposedITAT Mumbai11 Apr 2025AY 2004-2005

Bench: Shri Pawan Singh, Jm & Ms Padmavathy S, Am

Section 115JSection 80HSection 80I

Adjustment in respect of guarantee commission 31. The AO noticed that the assessee in the Transfer Pricing Report furnished under section 92E relating to International Transaction entered by the assessee with its Associated Enterprises (AE) that the assessee has not charged commission on guarantee given to its AE in Bangladesh ... addition by applying 0.8% as Guarantee Commission. 32. The ld. AR during the course of hearing fairly conceded that the impugned transactions are international transactions and made an alternate plea that the guarantee commission be restricted to 0.5% by relying on the following decisions: a. Cadilla Pharmaceuticals Ltd. vs. ACIT

Ariston Group India Private Limited, Pune vs. The Assessement Unit, Income Tax Department, NFAC and the DCIT, Circle 1(1), Pune

In the result, appeal of the assessee is partly allowed

ITA 1680/PUN/2024[2020-21]Status: DisposedITAT Pune09 Apr 2025AY 2020-21

Bench: Shri R.K.Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1680/Pun/2024 िनधा"रण वष" / Assessment Year: 2020-21 Ariston Group India Private The Assessment Unit, Limited, Income Tax Department, 1St Floor, Office No.103, V National Faceless Mayfai Tower, Wakdewadi, S. Assessment Centre, Shivaji Nagar, Pune-411005. Delhi(“Nfac”), The Dcit, Circle-1(1), Pune. Pan: Aaoca7042D Appellant/ Assessee Respondent / Revenue Assessee By Shri Ketan Ved – Ar Revenue By Shri Prakash L Pathade – Cit(Dr) Date Of Hearing 15/01/2025 Date Of Pronouncement 09/04/2025 आदेश/ Order Per Vinay Bhamore, Jm: This Is An Appeal Filed By The Assessee Against The Assessment Order Passed Under Section 143(3) R.W.S 144C(3) Read With Section 144B Of The Income Tax Act, 1961, Dated 18.06.2024 For A.Y.2020- 21. The Assessee Has Raised The Following Grounds Of Appeal : “Based On The Facts & Circumstances Of The Case, Ariston Group India Private Limited (Hereinafter Referred To As "Ariston India' Or 'The Appellant) Prefers An Appeal For The Assessment Year 2020-21 Against

Section 143(3)Section 144Section 144BSection 144C(13)Section 37(1)Section 92C

erred in law and on the facts and in the circumstances of the case in determining the arm's length price of the international transaction of payment of management fee as "NIL', thereby making a transfer pricing addition of Rs.6,53,65,772/- to the total income of the Appellant ... facts and in circumstances of the case erred in following different most appropriate method and benchmarking approach for the international transactions of 'Payment of management services' vis-à-vis 'Payment of IT support services though both these transactions are covered by single inter-company agreement and follow same pricing mechanism

Hammond Power Solutions Private Limited, Hyderabad vs. DCIT, Circle 2(1), Hyderabad

In the result, the appeal of the assessee is dismissed

ITA 76/HYD/2022[2017-18]Status: DisposedITAT Hyderabad09 Apr 2025AY 2017-18

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri Madhusudan Sawdia, Hon’Ble

For Appellant: Shri P.V.S.S. Prasad, C.AFor Respondent: Ms. M. Narmada, CIT-DR
Section 143(3)Section 92C

length nature of technical and stewardship services i.e., management services (intra group services) and thereby erred in determining the ALP for the following international transactions as Nil: • Technical Services Rs. 25,12,410 • Stewardship services Rs. 1,07,77,840 4. The Approach adopted by the Ld. DRP/AO of using ... Assessee filed its return of income for A.Y. 2017-18 on 30.11.2017 declaring a total income of Rs.97,15,600/-. In view of the international transactions involved during the year under consideration, for determination of Arms Length Price (“ALP”), the case was referred to Learned Transfer Pricing Officer

Aon Consulting Private Limited, New Delhi vs. DCIT, Circle-1(1), Delhi

In the result, appeal of the assessee is partly allowed in the terms aforesaid

ITA 739/DEL/2022[2017-18]Status: DisposedITAT Delhi09 Apr 2025AY 2017-18

Bench: Shri Vikas Awasthy & Shri Pradip Kumar Kediaआअसं.739/िद"ी/2022(िन.व. 2017-18) M/S Aon Consulting P. Ltd., Aon Centre, 9Th To 11Th, Building No.2, Unitech Realty Projects Ltd., (Sez), Village Tikri, Sector 48, Gurgaon, Haryana 122001 ...... अपीलाथ"/Appellant Pan: Aahca-0739-J बनाम Vs. Deputy Commissioner Of Income Tax, ..... "ितवादी/Respondent Circle 1(1), Delhi Assessee By : Shri Darpan Kirpalani, Advocate Department By : S/Shri Rajesh Kumar & Rajesh Kumar Dhanesta, Sr. Dr सुनवाई क" ितिथ/ Date Of Hearing : 17/01/2025 घोषणा क" ितिथ/ Date Of Pronouncement : : 09/04/2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed The Assessment Order Dated 22.02.2022 Passed U/S. 143 R.W.S. 144C(13) R.W.S 144B Of The Income Tax Act,1961(Hereinafter Referred To As ‘The Act’). 2. The Assessee In Appeal Has Assailed Transfer Pricing Adjustment Made In Respect Of Software Development Services Segment. The Assessee Has Also Assailed Some Additions On Corporate Issue, Viz. Disallowance Made U/S. 14A R.W.S. 8D & Additions Based On Intimation U/S. 143(1) Of The Act.

For Appellant: Shri Darpan Kirpalani, AdvocateFor Respondent: S/Shri Rajesh Kumar & Rajesh Kumar Dhanesta, Sr. DR
Section 143Section 143(1)Section 14A

over the globe. The assessee/appellant is captive services provider. During the period relevant to assessment year under appeal the assessee entered into several international transactions with its AE’s. The Transfer Pricing Officer (TPO) accepted all international transactions except international transaction of Software Development and Training Services and IT Enabled ... adjustment made by TPO under ITeS segment. 5. Shri Darpan Kirpalani, appearing on behalf of the assessee submits that the assessee had entered into international transaction aggregating to Rs.93,40,78,783/- under Software Development & Training Segment. The 3 assessee applied Transactional Net Method (TNMM) to bench mark international transaction

M/S. Ugs Finance Pvt. Ltd., New Delhi vs. DCIT, New Delhi

The appeal of the assessee is dismissed

ITA 1932/DEL/2016[2004-05]Status: DisposedITAT Delhi09 Apr 2025AY 2004-05

Bench: SMT. ANNAPURNA GUPTA (Accountant Member), MS MADHUMITA ROY (Judicial Member)

For Appellant: NoneFor Respondent: Ms Harpreet Kaur Hansra, Sr. DR
Section 148Section 271(1)(c)Section 68

account in the bank, they have declared that one more account be opened-with ABN Amro Bank New Delhi for accounting purpose of their international transactions But as per bank statement there is no international transactions were made. As per the declaration the group companies contains the following names

Schneider Electric India Pvt. Ltd., Gurgaon vs. ACIT, New Delhi

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 1076/DEL/2016[2007-08]Status: DisposedITAT Delhi09 Apr 2025AY 2007-08

Bench: Shri Vikas Awasthy & Shri Pradip Kumar Kedia[Assessment Year : 2007-08] Schneider Electric India Vs Acit Pvt.Ltd., 9Th Floor, Tower C Circle-22(2) Building No.10, Dlf Cyber Room No. 226 City, Phase-Ii, Gurgaon C.R. Building Hartyana-122002 New Delhi-110002 Pan-Aabcs1642G Appellant Respondent Appellant By Shri Rohit Tiwari, Adv. & Tanya, Adv. Respondent By Shri Rajesh Kumar Dhanesta, Sr.Dr Date Of Hearing 17.01.2025 Date Of Pronouncement 09.04.2025

Section 10ASection 143(3)Section 144CSection 92C(2)Section 92D

AO/Ld. TPO have erred on facts and in law in enhancing the income of the Appellant by INR 21.53.53.349 by holding that the international transactions pertaining to purchase of raw material, research and development (R&D) support services segment and business support services does not satisfy the arm's length ... necessarily available to the Appellant at the time of preparing its TP documentation; Purchase of raw material 2.3. failing to appreciate that the international transactions of the Appellant relating to import of components for manufacture of electrical equipment would meet the arm's length principle on a transaction-by-transaction

Lg Electronics India Private Limited, New Delhi vs. Deputy Commissioner of Income Tax -Circle 13(1), New Delhi

In the result, both appeals of the assessee are allowed for statistical purposes

ITA 2577/DEL/2024[2005-06]Status: DisposedITAT Delhi08 Apr 2025AY 2005-06

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishraआ.अ.सं/.I.T.A Nos.2577 & 2578/Del/2024 िनधा"रणवष"/Assessment Years: 2005-06 & 2006-07 बनाम Lg Electronics India Private Deputy Commissioner Of Limited, Income Tax, Circle-13(1), Vs. A-26/4, Mohan Cooperative C. R. Building, Industrial Area Estate, Mathura I. P. Estate, Road, New Delhi. New Delhi. Pan: Aaacl1745Q अपीलाथ" Appellant ""यथ"/Respondent

Section 271(1)(c)Section 40Section 80JSection 92C

after claiming the receipt of Rs.57,71,79,709/- from sales tax department as capital receipts. Since the assessee has undertaken certain international transactions with its AEs, the Assessing Officer referred the matter to the TPO under section 92CA(1) of the Act. The TPO vide order dated 31.10.2008 suggested ... upward adjustment of Rs.5,12,44,116/- being the arm's length price of the international transactions of contribution towards World Cup Tournament and an amount of Rs.18,66,31,111/- being the arm's length price of the reimbursement of advertising, marketing and sales promotion expenses. The Assessing Officer

Dr. Bhim Rao Ambedkar Mahasang Haryana, Faridabad vs. CIT (Exemptions), Chandigarh/Faridabad

In the result, both the appeals are partly allowed for statistical purposes

ITA 3196/DEL/2023[NA]Status: DisposedITAT Delhi08 Apr 2025

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarita No. 3195/Del/2017 Assessment Year: 2003-04 Ita No. 3196/Del/2017 Assessment Year: 2004-05 Geodis Overseas Pvt.Ltd., Vs. Asstt. Commissioner Of Building No.5,Tower B, Income Tax, 10Th Floor, Dlf Cyber City, Company Circle- Ii(1), Phase Iii, Gurgaon Chennai-34 Pin: 122 002 Pan No. Aaacc6168L (Appellant) (Respondent)

For Appellant: Shri Vishal Kalra, Adv. & ShriFor Respondent: Ms. Neeju Gupta, Sr. DR
Section 250Section 92C

Shri D.C.Gupta, Sr. Manager (Finance & Accounts) of the company appeared and filed details. 4. The assessee had international transactions exceeding Rs.5 crores with its associated enterprises. Hence the case was referred to the Transfer Pricing Officer under section 92CA(1) of the Act. The Transfer Pricing Officer passed order under ... section 92CA(3) on 22-02-2006 wherein he determined an adjustment of Rs.2,23,96,778/- to be made to the value of international transactions entered into by the assessee. Hence, a sum of Rs.2,23,96,778/- is reduced from the loss shown by the assessee

Dr Reddys Laboratories Limited, Hyderabad vs. Deputy Commissioner of Income-Tax, Circle-8(1), Hyderabad

In the result, the appeal filed by the assessee is dismissed

ITA 409/HYD/2023[2011-12]Status: DisposedITAT Hyderabad07 Apr 2025AY 2011-12

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri Manjunatha G., Hon’Bleआ.अपी.सं /Ita No.409/Hyd/2023 (िनधा"रण वष"/Assessment Year: 2011-12) Dr. Reddy’S Laboratories Deputy Commissioner Limited Vs. Of Income Tax Hyderabad Circle-8(1) [Pan: Aaacd7999Q] Hyderabad (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Shri S.P.Chidambaram, Ar राज" व "ारा/Revenue By: Shri B.Bala Krishna, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 09/01/2025 घोषणा की तारीख/Date Of 07/04/2025 Pronouncement: आदेश / Order Per. Manjunatha G., A.M: This Appeal Filed By The Assessee Is Directed Against The Order Dated 09.06.2023 Of The Learned Commissioner Of Income Tax (Appeals) [Ld.Cit(A)], National Faceless Appeal Centre, Delhi, Pertaining To A.Y.2011-12. 2. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Shri S.P.Chidambaram, ARFor Respondent: Shri B.Bala Krishna, CIT-DR
Section 115JSection 143(3)Section 147Section 148Section 154Section 234C

subjected to scrutiny assessment and during the course of assessment proceedings, a reference was made to Transfer Pricing Officer for determination of ALP on international transaction of the assessee with its AE. The TPO has not made any adjustment during TP proceedings towards interest income received from its AE. From

Capita India Private Limited, Mumbai vs. Assessment Unit, National Faceless Assessment Centre (NFAC), Mumbai

ITA 4954/MUM/2024[AY 2020-21]Status: DisposedITAT Mumbai07 Apr 2025
For Respondent: Shri Kiran Unavekar
Section 143(3)Section 144BSection 144C(13)Section 144C(5)Section 153Section 92C

thus making the assessment proceedings time barred and bad in law and thereby it should be quashed; A Transfer Pricing grounds in relation to international transaction of Provision of IT enabled services Reference to the TPO 3. erred in making a reference of the Appellant's case ... filter of 25% of the total revenues, 7. erred in rejecting Ultramarine & Pigments Limited considered to be comparable by the Appellant for benchmarking the international transaction of provision of IT enabled services on the basis that no separate segmental financials are available when separate segmental are available in the Annual